8.Cost and benefits of RCD virus introduction
| The cost benefit analysis in the Application is based on a report by Brown Copeland & Co Ltd who in their conclusion emphasise that: | |
| .....the information provided is only preliminary and at best, only indicative of the magnitude of the likely costs and benefits. Not only has the proposed release strategy not yet finalised, but the relationship between RCD and the dynamics of the rabbit population spatially and over time is very uncertain. Second order effects, for instance predator-prey relationships, are also not researched. In addition, primary data collection, which has not been possible within the scope of this contract, would be necessary to firm up on some of the parameter estimates. It is therefore recommended that once the results of ongoing technical research relating to RCD is completed, this economic analysis be updated to better reflect latest available information. | |
| Subject to these provisos, it is concluded that here is a considerable financial benefit to landholders in the semi-arid high country of the South Island for the introduction RCD compared with the situation likely to prevail with the continued use of conventional control technologies, but nationally the net financial benefits are probably not significant. However, from an environmental perspective the introduction of RCD has the potential to reduce degradation across large areas of the South Island hill and high country, with positive impacts on conservation values. From an international trade perspective also, the fact that RCD will result in reduced use of 1080 and other poisons is positive, but these advantages need to be balanced against the negative public perspective that exists about the risks associated with the introduction of biocontrol viruses into New Zealand. | |
The analysis of submissions showed that there were many general statements by supporters about the benefits of RCD, that it would save farmers and the economy many millions of dollars, and bring substantial benefits to farm families, the rural community and the environment, and that these have been understated in the Application.
On the other hand, there was also concern amongst those in opposition that many cost factors that have been understated.
The analysis of submissions showed a number of benefits (mainly by supporters) that might be included in any analysis:
- reduced expenditure on rabbit control,
- more attention to predator control,
- reduced bovine Tb (through reduced predators),
- increased stocking rates and farm productivity,
- increased farm expenditure on productive activities such as pasture development, fertiliser and subdivision, and weed control,
- increased opportunities for specialist crops,
- reduced risks to forestry plantings,
- reduced farm workloads, particularly at night,
- reduced family stress,
- reduced risks from firearm use,
- improved farm finances, debt reduction and easier budgeting,
- flow-on economic benefits to rural communities,
- reduced demand for taxpayer input to provide pest control and sustainable soil and water management,
- increased conservation values and
- reduced land, soil and water degradation with more sustainable land management.
Possible costs are also indicated (mainly by opponents) and these include:
- costs associated with preparation and distribution of the virus,
- administration of a release programme,
- training of staff for various roles in the programme,
- an increase in woody weed control and of consequent burn offs and chemical spraying,
- loss of the feral meat processing industry,
- reduced carrot production for aerial poisoning,
- ongoing costs of secondary control,
- effects on endangered and other species through prey switching,
- increased costs of predator control,
- establishment of base-line data before release,
- monitoring the distribution of RCD and the effectiveness of the programme,
- monitoring for infection in non-target species and humans,
- costs of mitigation for harm to non-target and people,
- protection of non-target rabbits including vaccination programmes.
| The New Zealand Conservation Authority has substantive concerns with the proposal to release RCD: | |
| "The benefits are well covered in the Application, the potential costs are not. These costs include both environmental impacts and monetary costs which will be incurred in programmes of monitoring, predator and weed control, research etc. To make a decision on an irreversible action such as this, the decision maker needs to be able to balance the costs and benefits of the proposal over both the short and long term. The document does not provide the balanced consideration of the costs and benefits which is essential for the consideration of the introduction of RCD. Consequently the Authority does not consider that the Application provides the decision maker with adequate information on the possible costs of the release of RCD to enable them to make an informed decision on the proposal at this time." | |
| It is argued by a number of submitters in opposition that the Application has no cost-benefit analysis and that this should be undertaken. They claim that: | |
| "no comprehensive, rational and substantiated costing of the problem is provided." (400) | |
| "The decision on the release of RCD should only be made with the benefit of a clear and full understanding of the both the costs and benefits of the introduction." (767) | |
A full cost benefit analysis would need to take account of both quantitative and qualitative information, and also an assessment of risks, including direct and indirect effects. It is argued that the analysis should look at the allocation of benefits and costs by sectors of society, and over time (a short term benefit for few for the long term cost of many). It may need to take both a national and various regional perspectives.
In view of the concerns raised by reviewers MAF commissioned a revision of the cost-benefit analysis by Brown Copeland and Co Ltd and this is appended in Appendix 1. No new data or factors have been presented which fundamentally alter the conclusions reached previously but the report better differentiates the "biological control" and "biocide" options.
However, it is very difficult to quantify all of the benefits and costs. Many of the perceived environmental and social benefits associated with RCD are not quantifiable.
8.2 Liability of the Crown
A number of submitters point out that there is no clarification of the Crowns liability, in particular for long term risks.
It is unlikely that the Crown would be liable for damage arising from a decision to introduce, or not to introduce RCD, provided that the decision-maker makes a considered decision based on the best available information.
If the RCD virus is introduced and some problem arises in the future the virus may be declared an unwanted organism and the provisions of the Biosecurity Act would apply.
Conclusion
I consider that the major beneficiary of effective biological control of the rabbit would be New Zealand "incorporated". The primary benefit would be for the preservation of New Zealands ecosystem and conservation values and not to individual farming businesses.
An RCD virus introduction would also result in significant costs. Exactly who would be expected to meet these costs should be agreed before the virus was imported.
References cited in the report
(Number) e.g. (477). This refers to the submitters number assigned during the public consultation process.
Allen, J., Buxton, P. P., Hewitt, A. E., Hunter, G. G. 1995. Effects of rabbits and hares on organisms, ecosystems and soils in terms of the Biosecurity Act. Landcare Research Contract Report: LC 9495/074.
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Barlow, N. D. 1996. Modelling RCD in rabbits. Unpublished report to MAF Policy.
Blancou, 1991. Revue Scientifique et Technique. Office International Des Epizooties. 10 (2): 265-266.
Boag, B. Dr. Scottish Crop Research Institute, Invergowrie, Dundee, DD2 5DA. United Kingdom. Reviewer.
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Burke, D. S. Walter Reed Army Institute of Research. Rockville, Maryland, United States of America. Reviewer.
Cancellotti, F. M. and Renzi, M. 1991. Epidemiology and current situation of viral haemorrhagic disease or rabbits and European brown hare syndrome in Italy. Revue Scientifique et Technique. Office International Des Epizooties. 10 (2): 409-422.
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Capucci, L., Fusi, P., Lavazza, A., Pacciarini, M. L. and Rossi, C. 1996. Detection and preliminary characterization of a new rabbit calicivirus related to rabbit haemorrhagic disease virus but nonpathogenic. Journal of Virology, Dec. 8614-8623.
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Chasey, D and Trout, R. C. Reference date unknown. Rabbit haemorrhagic disease in Great Britain. Appendix a of the Application.
Collins, B. J., White, J. R., Lenghaus, C., Morrisy, C. J. and Westbury, H. A. 1996. Prevalence of rabbit haemorrhagic disease virus antigen in rabbit tissues as revealed by a monoclonal antibody dependent capture ELISA. Accepted for publication in Journal of Virological Methods.
Cooke, B. D. 1996. Analysis of the spread of rabbit calicivirus from Wardang Island through mainland Australia. A report prepared for the Meat Research Corporation, October 1996, as part of Project CS. 236. "Field evaluation of RCD under Quarantine"
Crosby, T. K. and McLennan, J. 1996. Potential vectors of rabbit calicivirus disease (RCD) in New Zealand: a review. Landcare Research contract report LC9596/072 for MAF Policy, Wellington.
CSIRO-1 report, 1996. Field evaluation of rabbit calicivirus disease under quarantine. Project CS.236.
Cubitt. Dr D. Cubitt, Consultant Clinical Virologist, Great Ormond Street Hospital for Children, NHS Trust, London. United Kingdom.
DoC. Department of Conservation. P. O. Box 10-420, Wellington. Reviewer.
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Lektos Consulting Limited, Palmerston North. Reviewer.
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Additional Sources of Information used in the Preparation of the Report of the Chief Veterinary Officer
Information examined that may not have been specifically cited in preparing this recommendation
| 1. | The import impact assessment plus 18 volumes of appendices. |
| 2. | All of the public submissions. |
| 3. | Analysis of submissions on the importation impact assessment for the RCD virus. A report by Talyor Baines & Associates, prepared for the Chief Veterinary Officer, MAF. December, 1996. |
| 4. | All of the comments from the following reviewers who had specified expertise: |
| Department of Conservation (conservation of native flora and fauna); | |
| Ministry for the Environment (wider environmental concerns); | |
| Te Puni Kokiri (Treaty of Waitangi and Maori issues); | |
| Ministry of Health (human health); | |
| Ministry of Agriculture (science and wider agriculture, virology and pest management strategies). | |
| The Macaulay Land Use Research Institute of Aberdeen (Glenn Iason) (ecology); | |
| Ecosystems Consultants of Dunedin (Henrik Moller) (ecology); | |
| Mo Salman of the University of Colorado (veterinary pathology and epidemiology); | |
| Robert E Shope of the University of Galveston, Texas, USA, (virology and human health); | |
| Donald Burke of the Walter Reed Army Institute of Research, Maryland, USA, (virology and human health); | |
| Lektos Consulting Limited (retaining Professor B W Manktelow), of Palmerston North, (veterinary pathology); | |
| Brian Boag of the Scottish Crop Research Institute, Dundee, UK, (ecology); | |
| Massey University (Robin Fordham) of Palmerston North, (ecology). | |
| 5. | Comments made by 105 submitters on the reviewers reports. | |
| 6. | The Chief Veterinary Officer also met or spoke over the telephone with the following submitters during the period 6 to 23 May 1997: | |
| submission 531, | Graeme Milne, rabbit harvesting and resource recovery; | |
| submission 153, | Biotechnology Association of New Zealand, to discuss the potential impact of the introduction of RCD on New Zealands disease free status and biological exports. Max Kennedy, Vice-President, attended; | |
| submission 796, | Te Puni Kokiri, the views and interests of Maori; | |
| submission 176, | Ministry of Health, concerns about human health issues; | |
| submission 376, | Alvin Smith; host specificity of the family Caliciviridae; | |
| submission 673, | Douglas Gregg, of Plum Island Foreign Animal Disease Diagnostic Laboratory, USA, the parvovirus connection. | |
| submission 673, | Yvonne van Roy; | |
| submission 722, | Walter C Clark; | |
| submission 1000, | Neil Cherry; | |
| submission 362, | Elayne Ravji accompanied by Paul Tucker of the Directors of Friends of the Earth, submission 755, and Graeme Milne, submission 531; | |
| submission 674, | Royal Forest and Bird Protection Society, Sue Maturin attended. | |
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Contact for Enquiries
Manager, Strategic Science Team
MAF Biosecurity New Zealand
PO Box 2526
Wellington
NEW ZEALAND
Phone: +64 4 894 0115
Fax: +64 4 894 0731
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